July 20, 2011

VIA EDGAR

Division of Corporate Finance

United States Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549-3561

Attn:  Jeffrey Jaramillo

Re: New Energy Systems Group (the “Company”) - Comment Response Letter

Mr. Jeffrey Jaramillo:

Reference is made to the SEC Comment Response Letter of the Company, dated July 19, 2011 (the “Response Letter”), which was submitted to the SEC via EDGAR on July 19, 2011. As counsel to the Company, please note that the Company inadvertently excluded the supporting documentation referenced in the Response Letter. Accordingly, please find annexed hereto as Exhibit A such supporting documentation for your reference.

Very truly yours,
By:	/s/ Jennifer Ahn
	Jennifer Ahn, Esq.

61 Broadway    New York, New York  10006  212-930-9700  212-930-9725 Fax

www.srff.com

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EXHIBIT A

New Energy Systems
Anytone
Assets	Carrying Value on Dec 31, 2010		Liabilities	Carrying Value on Dec 31, 2010		Future discounted cash flow, income approach, per appraisal report
Total Identifiable Assets		24,083,000	Total Liabilities		31,216,000
Investment into subsidiary		28,000,000
Goodwill		20,449,000					41,477,041
Total Fair Value of Reporting Unit		41,477,041	Net asset including goodwill per book		41,316,908

Newpower
Assets	Carrying Value on Dec 31, 2010		Liabilities	Carrying Value on Dec 31, 2010
Total Identifiable Assets		10,487,000	Total Liabilities		2,521,400
Goodwill		13,564,000				21,618,071
Total Fair Value of Reporting Unit		21,618,071	Net asset including goodwill per book		21,530,397

Kimfai
Assets	Carrying Value on Dec 31, 2010		Liabilities	Carrying Value on Dec 31, 2010
Total Identifiable Assets		4,860,000	Total Liabilities		2,792,900
Goodwill		26,541,000				25,954,037
Total Fair Value of Reporting Unit		25,954,037	Net asset including goodwill per book		28,608,276

61 Broadway    New York, New York  10006  212-930-9700  212-930-9725 Fax

www.srff.com

2